Privacy Policy

Effective Date: July 4, 2024

INTRODUCTION AND SCOPE

This Privacy Policy is issued on behalf of WNR AI (“WNR AI”, “we”, “us”, and “our”) and governs the personal data (as defined below) collected from or processed about you when you use the WNR AI online platform, including by uploading images, selecting and customizing AI Twins, and any other interactions with our service (collectively referred to herein as “Use”).

We provide this Privacy Policy to explain our practices for collecting, using, processing, and disclosing the personal data we process about users of WNR AI (“users”, “you”, or “your”, as applicable), and to inform you of your rights regarding your personal data and choices you can make in relation to it. By personal data, we mean (i) information that is associated with an identified or identifiable natural person, and (ii) protected as personal data under applicable data protection laws.

This Privacy Policy applies to personal data we or any third party collects from you offline or on any other platforms or websites operated by WNR AI.

Please read this Privacy Policy carefully to understand our privacy practices. We also encourage you to review our Terms of Service to understand how we provide services to you. For information on how we process photos in connection with the features of our platform, including the AI Twin generation, please see Section 3: How We Process, Share and Retain Your Photos, Videos, and Image Data.

If you do not want us to process your personal data as described in this Privacy Policy, please do not use WNR AI.

Questions? If you have any questions about this Privacy Policy or WNR AI, please contact us at [email protected]

U.S. State Supplements:

  • If you are a resident of the U.S. state of California, please see our California Notice at Collection and Privacy Notice.
  • If you are a resident of the U.S. state of Connecticut or Colorado, or a resident of the U.S. Commonwealth of Virginia, please see our U.S. State Privacy Supplement (Non-California).

1. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

We may collect personal data from and about you:

  • Directly from you when you provide it to us.
  • Automatically when you use WNR AI. Information collected automatically may include usage details and internet protocol (“IP”) addresses.
  • From third parties, for example, our service providers, partners, and vendors.

2. PERSONAL DATA YOU PROVIDE TO US DIRECTLY

You may provide personal data to us directly, or to service providers acting on our behalf, when you use WNR AI. The personal data you provide depends on which features of WNR AI you use and how you interact with our platform.

  • Photos and/or videos that you upload to WNR AI. If you grant us permission to access your device’s photo library, we will process the photos and videos you select to upload to WNR AI to provide features of the platform that you choose to use. For more information regarding how we process your photos and videos, please see Section 3: How We Process, Share and Retain Your Photos, Videos, and Image Data.
  • Account Information. When you create an WNR AI account, we ask you to provide your email address. If you log in via third-party services (such as Google or Facebook), we may receive your associated email address or other profile information depending on your settings with the third-party service.
  • If you contact us or communicate with us, we will collect and receive records and copies of your correspondence with us, and contact details that you provide while making your inquiries (such as your name, postal addresses, email addresses, and phone numbers, or any other identifier by which you may be contacted).

3. HOW WE PROCESS, SHARE, AND RETAIN YOUR PHOTOS, VIDEOS, AND IMAGE DATA

We process your photos and videos to provide you with the features of the WNR AI platform that you choose to use. In doing so, when you upload photos or videos to WNR AI, we process your photos and videos using technology that identifies data within the photos and videos, providing us with information such as facial position, orientation, topology (“Face Data”), and other elements of your photo (collectively, “Image Data”). The following describes how we process, share, and retain your photos, videos, and Image Data in connection with various features of WNR AI. Please note that we may retain your data for longer time periods than set forth below where required to do so by law.

AI Twin Generation. When you upload photos for creating your AI Twin, we apply technology to generate Image Data. This processing occurs on our servers. Customization Features. If you use customization features (e.g., astronaut, firefighter) on an AI Twin, we apply technology to generate Image Data based on your selections.

Data Usage for AI Improvement. While we do not use your personal data to train or create separate artificial intelligence/products, we may use anonymized and aggregated Image Data to improve the AI models and algorithms that power WNR AI. This does not include any personal identifiers.

Retention of Generated Images. Your generated images, such as AI Twins or customized images, are stored on our servers (provided by [Your Server Provider, e.g., Amazon Web Services (USA)]) and are available to you within the WNR AI platform at any time, via any device with which you log into WNR AI, until you decide to either (i) delete the images or (ii) delete your WNR AI account. If you delete an image, we will generally process the deletion within [Specify Time Frame]. If you delete your WNR AI account, we will generally delete your account, including all generated images in your account, within twenty-four (24) hours. Please be aware that discontinuing the use of WNR AI does not result in the deletion of your WNR AI account.

4. THE PURPOSES AND OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

  • We use your personal data for a variety of purposes depending on the category of personal data and the way you use and interact with the WNR AI platform, including the following:
  • To present to you and others WNR AI and its contents, and any other information, products, or services that you request from us, including to provide various features of the platform (e.g., AI Twin generation, image customization). We do this to provide you with the services subject to your explicit consent and according to our contractual obligation.
  • To fulfill our obligations and enforce our rights arising from any contracts entered into between you and us in relation to WNR AI (e.g., the Terms of Service). This is for the performance of our contract with you and for our legitimate interests in performing and enforcing our contracts with you and/or to defend our rights in case of claims.
  • To customize our product and service offerings to you. This may involve automated decisions using data such as device type and language settings. Where required by law, we rely on your consent to offer such personalization and/or offer you the opportunity to opt-out.
  • To provide customer and technical support, investigate your concerns, respond to your inquiries, and to monitor and improve our responses. It is in our legitimate interest to provide you with high-quality support.
  • To communicate with you about changes to WNR AI or any products or services we offer or provide through it, including by sending you technical notices, updates, security alerts, and support and administrative messages. It is our legal obligation and legitimate interest to keep you informed about your account and our services.
  • To conduct research, analytics, and monitor performance and other metrics regarding WNR AI and your use of it. This helps us understand our business metrics and improve our product. Where this data is collected through technologies described in Section 7, and where required by law, we rely on your consent; otherwise, it is our legitimate interest to conduct such analytics.
  • To improve, test, and monitor the effectiveness of WNR AI. It is in our legitimate interest to understand and enhance our product and business metrics.
  • To provide personalized content and information to you and for advertising purposes. This may include using your personal data to build targeted advertising audiences. Where required by law, we rely on your consent for such activities and/or offer you the opportunity to opt-out.
  • To send marketing and promotional communications to you with your consent or as otherwise permitted by law.

In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.

As permitted or required by law, including for auditing, fraud and security monitoring purposes.

5. TO WHOM WE DISCLOSE PERSONAL DATA

  • We may disclose the information we process about you, including any personal data, as follows:
  • We may share your personal data with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries (“Affiliates”). These Affiliates act as our data processors and may perform data processing on our behalf (e.g., providing technical support or conducting analytics). They are bound by appropriate contractual safeguards.
  • We may disclose your personal data to third-party organizations such as contractors, business partners, service providers, and vendors that support our business and assist us in providing WNR AI. Such service providers may include cloud providers for data storage and analytics platforms.
  • We may disclose your personal data to third-party analytics providers and advertising partners or permit them to collect or access it. For more information, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.
  • We may disclose your personal data in the event that we or any of our affiliates, subsidiaries, or lines of business is merged, acquired, divested, financed, sold, disposed of, or dissolved, including in transactions like mergers, divestitures, restructurings, acquisitions, bankruptcies, dissolutions, liquidations.
  • We may disclose your personal data in response to legal requests and for preventing harm. This includes responding to legal, government, or regulatory requests and sharing information when necessary to detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others; and prevent death or imminent bodily harm.

Information we receive about you may be accessed, processed, and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

6. COOKIES, SOFTWARE DEVELOPMENT KITS, AND OTHER TRACKING TECHNOLOGIES

When you use WNR AI, we and our service providers, vendors, and partners, including third parties, may use cookies (small text files placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your use of WNR AI. We also utilize third-party analytics tools like Google Analytics, Facebook Analytics, and other similar platforms to help measure traffic and usage trends for our service and for other purposes. These analytics tools collect information through third-party SDKs incorporated into our platform, including information about features of WNR AI you visit or use, your actions on WNR AI, and any subscription-related information. This information may be used to provide content, advertising, or functionality, or to measure and analyze ad performance on WNR AI or other websites or platforms. Third parties may also use such information for their own purposes. We do not use image data uploaded by users for advertising purposes.

Interest-based Advertising. We may collaborate with ad networks and other ad-serving providers who serve ads on behalf of us and others on non-affiliated platforms. Some of these ads may be personalized, designed to be relevant to you based on information ad networks and ad serving providers collect about your use of the platform over time, including information about relationships among different browsers and devices. This form of advertising is known as interest-based advertising.

Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You have the option to set your browser and device to limit such technologies. Visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info for information about interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program. For mobile app-specific opt-out options, visit http://www.aboutads.info/appchoices. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) at http://optout.networkadvertising.org/?c=1#!/. Opting out of interest-based ads does not stop ads from being served to you, but they will not be tailored to your perceived interests.

For users in the European Economic Area, United Kingdom, and United States, you can opt out of the processing of Personal Data via cookies, SDKs, and other tracking technologies by sending a request to [email protected].

Be aware that disabling cookies or similar tracking technologies may prevent you from accessing some of our content and affect the functionality of parts of our platform. Your choices are typically specific to each device and browser.

7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Access, Modification, Correction, and Erasure. You can contact us at [email protected] to request access to, modification, correction, update, erasure, or portability of any Personal Data that you have provided to us and that we hold about you. You can also request the deletion of your account.

EEA/UK Individuals. Individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain statutory rights in relation to their Personal Data under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the UK version of the EEA GDPR (“UK GDPR”) (collectively, “GDPR”), including the rights detailed below. Exercise these rights by contacting us (for contact information, see Section 22 How to Contact Us of the Terms of Service). We aim to accommodate your request or objection, but please note that not all rights are absolute.

  • Access to Your Personal Data: You have the right to request information about whether we hold any Personal Data about you and to receive a copy of such Personal Data.
  • Rectification of Your Personal Data: If you believe that your Personal Data is incomplete or inaccurate, you have the right to ask us to correct such Personal Data.
  • Restriction of Processing: You have the right to demand restriction of processing of your Personal Data in certain circumstances.
  • Erasure of Your Personal Data: In certain circumstances, you may ask us to erase your Personal Data.
  • Portability of Your Personal Data: You have the right, in certain situations, to receive the Personal Data you provided us in a structured, commonly used, and machine-readable format and to request the transfer of this data to another party.
  • Objection to Processing or Use of Your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to this processing or use.
  • Withdrawal of Consent: Where you have provided consent for the processing of your Personal Data for a specific purpose, you have the right to withdraw that consent at any time.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or the location of an alleged infringement of the applicable data protection law.

We may need to request specific information from you to help us confirm your identity when exercising any of the aforementioned rights. This is to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally, it may take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Please note that we will not discriminate against you for exercising your rights under the law.

8. YOUR CHOICES ABOUT OUR COMMUNICATIONS WITH YOU

If you are using WNR AI, you may receive electronic communications from us (e.g., via email, in-platform notifications, or push notifications). We send some communications, such as those related to your account, technical and security notices, and updates to the Privacy Policy and Terms of Service, as necessary to perform our contract with you to provide WNR AI or based on our legitimate interest in contacting you.

If required by law, we will ask for your consent to send you promotional and marketing emails, in-platform communications, and push notifications about new products, features, or offers from WNR AI and its affiliates.

9. DATA SECURITY

We use reasonable and appropriate security measures to protect your personal data and to prevent it from accidental loss, unauthorized access, use, alteration, and disclosure. However, the transmission of information over the internet is not entirely secure. While we strive to protect your personal data, we cannot guarantee its absolute security. Any transmission of your personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in WNR AI.

The safety and security of your information also depend on you. We are not responsible for how you choose to share the images, AI Twins, or any other information processed through your WNR AI account, such as on social media platforms. We are not responsible for the functionality, privacy, or security measures of any other organization.

10. DATA RETENTION

Apart from what is stated in Section 3: How We Process, Share and Retain Your Photos, Videos, and Image Data, we generally retain your personal data until you delete your WNR AI account. If you delete your WNR AI account, we aim to delete your account and associated data within a reasonable timeframe.

To request deletion of your WNR AI account, please contact us at [email protected] or proceed through WNR AI settings.

Notwithstanding the above, we may retain your personal data, images, AI Twins, and any other data for longer periods as necessary to comply with legal obligations, resolve disputes, or enforce our agreements. Even after deleting some or all of your personal data, we may continue to retain and use anonymized data previously collected that no longer identifies you.

11. CHANGES TO OUR PRIVACY POLICY

The date this Privacy Policy was last updated is at the top of this page. We may modify or update this Privacy Policy from time to time. Some changes do not require your consent, but if changes may affect your rights and freedoms significantly, we will obtain your consent for those changes separately from this Privacy Policy.